Permanent Establishment Profit Attribution: United Kingdom Courts Examine the ”Authorised OECD Approach”
Journal
International; OECD; United Kingdom
Bulletin for International Taxation 2019 (Volume 73), No. 6/7
The author, in this article, considers the implications of the functionally separate enterprise concept under the Authorised OECD Approach to the attribution of profits to permanent establishments with reference to tax treaties as analysed in two UK tax cases, Irish Bank Resolution (2017) and Bloomberg Inc (2018).